The following request for an investigation into problems at Gibe 3 Dam was filed by Friends of Lake Turkana Compliance Review and Mediation Unit registered the request. A mediation process has been initiated, and a meeting between Bank staff and Friends of Lake Turkana is scheduled for June 10 in Nairobi.
Mr. Per Eldar Sovik
Compliance Review and Mediation Unit (CRMU)
African Development Bank
Dear Mr. Sovik:
I am writing in my capacity as chairperson of Friends of Lake Turkana (FoLT), a community association formed in 2008 in response to threats to the viability of the world’s largest permanent desert lake in northwestern Kenya and southwestern Ethiopia. FoLT’s membership consists of people from the Lake Turkana region, where an estimated 300,000 people rely in some way on the lake for their livelihood and survival; virtually all of them are from ethnic groups often described as “indigenous.” (These groups include the Rendille, Samburu, Turkana, Elmolo, Dassanach, Ariaal, and Gabbra.) These peoples are usually described as pastoralists, but their lifestyles also include cultivation and, in some cases, fishing – activities which are possible only because of the lake. Indeed, even our herding activities are intimately bound up with the fragile ecosystem in which Lake Turkana is a dominant element.
We understand that the Executive Board of the African Development Bank (AfDB) is tentatively scheduled to consider financing to the Government of Ethiopia for the Gibe III hydropower dam on February 25, 2009. We believe that poor analysis and exclusion of the Turkana people in project preparation to date has violated multiple Bank policies, including its: Environmental and Social Assessment Procedures, Policy on Poverty Reduction, Resettlement Policy, Public Disclosure Policy, and Policy for Integrated Water Resources Management. We wish to formally request that the Compliance Review and Mediation Unit (CRMU) of the African Development Bank intervene in the Bank’s pending consideration of finance for the Gibe III hydroelectric project on the Omo River in Ethiopia.
The Gibe III Dam would have a serious impact on the flow and volume of the Omo River, which provides some 80% of the Lake’s replenishing inflow. We have reviewed the Environmental & Social Impact Assessment, including the Additional Study of the Downstream Area, approved by the Ethiopian government in July 2008 and find these documents seriously flawed. Indeed, the impact of Gibe III on Lake Turkana is barely acknowledged, and then only to be dismissed with spurious claims that the project will benefit the lake. These documents provide little scientific analysis regarding potential changes to the river flow, volume, and chemical balance. Analysis of the impacts of reservoir evaporation rates to downstream volumes also does not seem sound. There is no discussion of impacts from proposed irrigation schemes and two future large dams, Gibe IV and Gibe V.
No discussion of the duration or methodology of reservoir filling is provided. This could result in a prolonged dry season downstream, where the suggested environmental flow of 25m3/second, a rate equal to the single lowest monthly flow recorded in nearly four decades, could be implemented for well over a year. Such a potential experience could devastate the level of Lake Turkana.
A study by the Africa Resources Working group indicates that the completion of Gibe III could mean a drop in Lake Turkana’s depth of between seven and ten meters. Resulting changes in the lake’s chemical balance threaten the fish as well as other species (Nile crocodiles, hippopotamus, etc) that make Lake Turkana a valuable source of biodiversity. The economic devastation that would accompany such impacts would almost certainly mean a significant upswing in the violent conflicts that have often engulfed the region’s peoples.
We note that these oversights directly contradict the AfDB’s Policy for Integrated Water Resources Management (see specifically Section 4.2.2, which calls for assessment of transboundary waters and steps to avoid conflicts resulting from project impacts).
We did not learn about Gibe III from the Kenyan or Ethiopian government, official project developers or from the African Development Bank. Indeed we believe that no effort has been made by anyone involved in the project to officially inform or consult with the populations that would be affected by Gibe III’s impacts to Lake Turkana. Instead, we learned about the construction of Gibe III through concerned academic researchers. We have since worked with international NGOS, namely International Rivers, Campagna per la Riforma della Banca Mondiale and Bank Information Center, to gather and analyse project information, and to engage with Bank staff regarding our concerns.
Our efforts to discuss this matter with relevant AfDB staff, led by Ms. Terri Hathaway of the organization International Rivers, have been stymied. Facilitated by Ms. Hathaway, we began corresponding with Mr. Emmanuel Nzabanita on December 11 2008, requesting a conference call during which our questions and concerns could be addressed. After numerous delays in setting up this conversation, we were distressed to receive a note from Mr. Nzabanita on January 30, 2009 in which he regretted that “we are unable to hold the teleconference involving various organizations as suggested” – though no explanation for that inability was offered. He instead offered a short list of responses to some of the issues that had been raised in anticipation of the call. We found his responses selective and grossly inadequate. We are particularly concerned that Bank staff have so far ignored concerns we have raised since December regarding impacts to Lake Turkana, the lack of transboundary agreements, and the lack of consultation with affected peoples. (The memo sent by Ms. Hathaway and Mr. Nzabanita’s response may be viewed here .)
Since November 2008, FoLT have been working diligently to learn from the Kenyan government the extent of consultations and agreements between it and the Ethiopian government, both with regard to the impact of Gibe III on Kenya’s environment and peoples and the widely-reported presumption that much of the energy generated by Gibe III will ultimately be sold to Kenya. We have made progress in pushing inquiries at the parliamentary and ministry level; when we have firm answers, and, hopefully, official documentation, we will of course avail these to the CRMU.
We wish to note at the outset that we are conscious that, in addition to its impact on the Kenyan environment and peoples, Gibe III will have serious negative impacts within Ethiopia. We regret that we have been unable to make concrete connections with our counterparts on the Ethiopian side of the border; the restrictive nature of the Ethiopian government and the isolated nature of the region have delayed effective interactions. We anticipate that our request will be followed shortly by a complementary request to the CRMU from a number of groups concerned about Gibe III’s effects in Ethiopia.
We are therefore requesting that CRMU undertake, with urgency, investigation and mediation efforts which will ensure that affected communities are consulted and their interests and welfare taken into account before the Gibe III project is submitted to the AfDB Executive Board for consideration. We make this request on behalf of the Kenyan communities living in the vicinity of Lake Turkana, but also strongly believe that communities living in the Omo River delta region in Ethiopia have not been adequately consulted, are inhibited from learning and speaking about the project, and should receive the same consideration we are now seeking from the AfDB.
Friends of Lake Turkana